Memorandum from the Road Haulage Association
(RHA) (DDD 18)
The Road Haulage Association (RHA) is the trade
and employers association for the hire-or-reward sector of the
road haulage industry. The RHA represents some 8,000 companies
throughout the UK, with around 100,000 HGVs and with fleet size
and driver numbers varying from one through to thousands.
The RHA provides advice and guidance to member
companies on management and employment issues. We recommend a
zero tolerance approach to alcohol and drug abuse at work by workers
in safety-critical roles, including driving, which should be viewed
as gross misconduct most likely leading to dismissal. Clauses
to that effect are contained in the RHA Contracts of Employment
service which is available to all members.
We are grateful for the opportunity to contribute
to the debate on the possible reform of the drink and drug driving
laws, which follows the publication of the report by Sir Peter
North in June 2010.
We have set out our views below, relating points
to the questions specifically raised by the Transport Select Committee.
Our views have been formulated following consultation with RHA
members.
Should the permitted blood alcohol limit be reduced
as proposed?
Yes. As a keen supporter of proportionate road
safety measures and noting that only the UK and Malta within the
EU now maintain an 80mg per 100 ml of blood alcohol limit, the
RHA agrees with the proposal in the North report to reduce the
limit to 50mg.
When surveyed a majority of RHA members supported
the proposal to reduce the current limit from 80mg of alcohol
to 50mg per 100 ml of blood.
We have considered the suggestion that the new
limit would be applied to all drivers with no lower limit for
HGV or other professional drivers. We support this approach.
Of those members who responded to our survey
most were against a separate, lower limit for professional drivers.
If so, is the mandatory one year driving ban appropriate
for less severe offenders, at the new (lower) level?
The RHA does not support an automatic one year
driving ban at the new lower limit.
Of those RHA members agreeing with the introduction
of the lower limit of 50mg, most did not want to see an automatic
driving ban come in for those caught over the lower limit.
In circumstances where a driver had been convicted
at the new lower limit but had not been banned by the courts from
driving, our members would prefer to deal with such an employee
through disciplinary procedures up to and including dismissal.
We note that North suggests that under a new
regime HGV or other professional drivers found breaking any new
50mg limit would face stiffer penalties at court than other drivers.
While we agree that any breach of the reduced limit, however minor,
should be viewed very seriously in the case of a professional
driver we are of the view that it should be up to the courts to
decide on the imposition of a driving ban, after considering all
the circumstances.
How severe is the problem of drug driving and
what should be done to address it?
We have no comments about the prevalence of
drug driving in the general population; however we have tried
to assist the Committee by auditing RHA members for their experience.
We have asked our members about the extent of the drug driving
problem in their fleets and found that the vast majority do not
test for drugs currently.
We found that the majority do not test drivers
and at the same time do not think there is a drug use problem.
Of members responding a small proportion do
test for drugs currently and having tested think there is
no significant problem.
A substantial minority of RHA members do
not test drivers currently but suspect there is a significant
problem.
A tiny proportion do test and as a result
think there is a problem.
What wider costs and benefits are likely to result
from changes to drink and drug driving law?
We note that North estimates that a reduction
in the drink drive limit could save up to 168 deaths in the first
year of implementation and 303 lives by the sixth year. The RHA
would welcome such a reduction in road deaths and does not anticipate
any serious long term dis-benefits in the context of the haulage
industry since responsible hauliers do not support a drink-drive
culture amongst their employees.
With regard to drug driving it is more difficult
to come to a firm conclusion given that there is limited evidence
about the extent problem, however again the RHA and its members
would welcome measures that lead to improved road safety.
The specific benefits for RHA members and to
wider society of the proposals in addition to increased road safety
and a reduction in road deaths could be as set out below:
— A reduction in costs to the NHS.
— A reduction in costs to the emergency
services.
— Reduced congestion costs/delay resulting
from a reduction in the number of road accidents.
— Increased public awareness of the hazards
of alcohol and drug consumption.
— Possible increase in business for taxi
firms.
— Possible reductions in insurance premiums
for fleets that test drivers for drink and drugs.
— A reduction in sickness absence from
work.
— Encouragement of more professionalism
amongst truck drivers.
The possible costs of any change might be as
set out below:
— Increased police costs in relation to
testing and enforcement.
— Increased court costs in relation to
prosecutions and appeals (these may reduce as the new rules and
culture become embedded).
— Damage to the pub trade in rural areas.
— Increased recruitments costs to businesses
which have to hire replacement drivers when the changes are first
introduced.
— Increased cost to hauliers for training
replacement drivers when new rules are first introduced.
What would be the implications of such changes
for enforcement?
At the initial stage after implementation of
a new regime there is a chance that confusion over the amount
of alcohol that can be consumed to keep within the new lower limit
blood alcohol might result in enforcement problems for the police
as well as more appeals in the courts. Similar problems might
arise, particularly in relation to consumption of prescription
drugs, if there was greater enforcement in relation to drug driving.
Such problems may well diminish over time as the public becomes
accustomed to the new regime.
August 2010
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